Chapman
Engineering
July 2007 Newsletter
Storm-Water Permits for Petroleum Bulk Plants
TCEQ has checked several of our client’s bulk plants, related to storm-water rules. A bulk plant
owner/operator has three options under these rules. Number one: it can be registered under the “multisector
industrial storm-water general permit.” Number two: it can be registered under the storm-water
permit for petroleum bulk stations. Or, number three, and what we recommend whenever possible, it can
avoid registering by NEVER discharging storm water that might be petroleum-affected.
U. S. EPA will implement the SPCC rule changes in October of this year. One of the most important
changes in these rules is that secondary containment must be put in place around bulk dispensing racks and
other product transfer areas. This means you have to detain rain water that comes into contact with those
product transfer areas, just as you already do with the tank batteries. If you detain storm water from these
containment areas and let it evaporate, then the facility is not discharging any water that might be
contaminated by petroleum.
Why go “no discharge?” One reason: it’s far less expensive over time to operate! If you register under a
storm-water permit, then you have to sample and analyze detained water, and show it’s clean, before you
can discharge it. Imagine how many rainfalls you get over time, and how many sampling events this leads
to. And you must document how much water you release, keeping good records, of course. And if the
water sample comes back “hot,” you hire a vacuum truck service to get rid of the contaminated water –
costly, too.
Cathodic Protection Testing
As a reminder, EPA and TCEQ rules require cathodic protection system testing once every three years. We
recommend annual testing, especially if you’ve had construction on site that may have damaged wires or
other equipment. Your pollution liability insurance company will want copies of test results to renew your
insurance, too.
Thanks as always for your business, and call us with any questions or comments at 800-375-7747. Do you
want to refer us to a friend?
|